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H2020 – LC-SC3-ES-5-2018-2020

Innovation Action

TSO-DSO-Consumer INTERFACE aRchitecture to provide innovative Grid

Services for an efficient power system

This project has received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement No 824330

D9.12 Report on the Foundations for the adoptions

of New Network Codes 1

Report Identifier: D9.12

Work-package, Task: WP9 Status – Version: 1.0 Distribution Security: CO Deliverable Type: R

Editor: EUI

Contributors: Valerie Reif, Athir Nouicer, Tim Schittekatte, Vincent Deschamps and Leonardo Meeus Reviewers: AGEN, ENTSO-E

Quality Reviewer:

Keywords: Data management, data exchange, interoperability, independent aggregators, demand-side flexibility, network codes, Clean Energy Package Project website: www.interrface.eu

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C

Copyright notice

© Copyright 2019-2022 by the INTERRFACE Consortium

This document contains information that is protected by copyright. All Rights Reserved. No part of this work covered by copyright hereon may be reproduced or used in any form or by any means without the permission of the copyright holders.

This deliverable reflects the Consortium view, whereas EC/INEA is not responsible for any use that may be made if the information it contains.

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Table of Contents

ABBREVIATIONS ... 6

EXECUTIVE SUMMARY ... 9

1. INTRODUCTION ... 13

THE LINK TO THE RESEARCH DOMAINS IDENTIFIED IN INTERRFACE DELIVERABLE “D2.4 COMPLETED REGULATORY FRAMEWORK” AND TO OTHER ACTIVITIES IN WP9 ... 14

RESEARCH METHODOLOGY ... 15

RELEVANCE FOR OTHER WORK PACKAGES IN INTERRFACE ... 16

2. DATA EXCHANGE AND INTEROPERABILITY ... 17

NETWORK, MARKET AND CONSUMER DATA AND DATA EXCHANGE IN EXISTING EU LEGISLATION ... 17

Framework to discuss the issues related to data ... 17

Applying the framework to network and market data ... 20

Applying the framework to consumer data ... 32

NEW EU LEGISLATION: GETTING OUR ACT TOGETHER ON THE EU INTEROPERABILITY ACTS ... 43

Introduction ... 43

The EU interoperability acts should be ambitious in addressing the multiple dimensions of interoperability ... 44

Experiences with interoperability in electricity and healthcare ... 46

Governance recommendations ... 49

3. DEMAND-SIDE FLEXIBILITY ... 52

3.1. TAKING STOCK OF THE REGULATORY FRAMEWORK FOR INDEPENDENT AGGREGATORS ... 52

3.1.1. Introduction ... 52

3.1.2. Aggregation and the role of the independent aggregator ... 54

3.1.3. Illustration: impacts of DR activation on the supplier and its BRP ... 57

3.1.4. Compensation to the supplier’s BRP ... 59

3.1.5. Compensation to the supplier ... 60

3.1.6. General implementation issues ... 68

3.1.7. Conclusion and recommendations ... 70

3.2. THE ECONOMICS OF EXPLICIT DEMAND-SIDE FLEXIBILITY IN DISTRIBUTION GRIDS ... 72

3.2.1 Introduction ... 72

3.2.2 Methodology ... 73

3.2.3 Case study and results ... 77

3.2.4 Conclusions and policy implications ... 88

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List of Tables

TABLE 1:MAPPING OF ASPECTS WE DISCUSS RELATED TO NETWORK AND MARKET, AND CONSUMER DATA TO THE FIVE

INTEROPERABILITY LAYERS OF THE SGAM FRAMEWORK ... 10

TABLE 2:MAPPING OF ASPECTS WE DISCUSS RELATED TO NETWORK AND MARKET, AND CONSUMER DATA TO THE FIVE INTEROPERABILITY LAYERS OF THE SGAM FRAMEWORK ... 18

TABLE 3:SELECTED USE CASES AND RELEVANT TYPES OF DATA ... 21

TABLE 4:OVERVIEW OF THE DIFFERENCES BETWEEN MARKET AND NETWORK DATA ... 25

TABLE 5:MAPPING OF SELECTED EXPERIENCES WITH INTEROPERABILITY IN THE ELECTRICITY SECTOR ONTO COMMON ASPECTS OF INTEROPERABILITY FRAMEWORKS INTRODUCED IN THE PREVIOUS SECTION OF THIS PAPER ... 47

TABLE 6:SUMMARY OF THE THREE MODELS TO COMPENSATE THE SUPPLIER ... 66

TABLE 7:SUMMARY OF THE PROPERTIES OF THE THREE SUPPLIER COMPENSATION MODELS ... 68

TABLE 8:PARAMETERS IN THE REFERENCE SCENARIO ... 79

TABLE 9:FLEXIBILITY LEVELS AND WELFARE GAINS FOR DIFFERENT SHARES OF PROSUMERS ... 84

TABLE 10:FLEXIBILITY LEVELS AND WELFARE GAINS FOR DIFFERENT COMPENSATION LEVELS ... 855

TABLE 11:FLEXIBILITY LEVELS AND WELFARE GAINS FOR DIFFERENT VOLL LEVELS ... 866

TABLE 12:FLEXIBILITY LEVELS AND WELFARE GAINS FOR DIFFERENT FREQUENCIES OF CRITICAL DAYS ... 877

TABLE 13:FLEXIBILITY LEVELS AND WELFARE GAINS FOR DIFFERENT NETWORK EXPANSION COSTS ... 888

List of Figures

FIGURE 1:INTERRELATION BETWEEN INTERRFACE TASKS 2.4,9.2 AND 9.4 LED BY FSR/EUI ... 14

FIGURE 2:HIGH-LEVEL ILLUSTRATION OF DATA EXCHANGE PROCESSES FOR CAPACITY CALCULATION PURPOSES PURSUANT TO ART.27-30 OF THE CACMGL ... 22

FIGURE 3:ILLUSTRATION OF HARMONISED ROLES IN THE HEMRM RELEVANT FOR DELIVERY OF GRID MODELS ... 24

FIGURE 4:SGAM INFORMATION LAYER DISPLAYING COVERAGE OF COMMON INFORMATION MODEL STANDARDS AND RELATED BUSINESS PROCESSES (MODIFIED FROM (ENTSO-E2018B)) ... 27

FIGURE 5: CARBON INTENSITY [GCO2EQ/KWH] OF ELECTRICITY CONSUMPTION IN EUROPE, (SOURCE: HTTPS://WWW.ELECTRICITYMAP.ORG, SCREENSHOT TAKEN ON 19/5/2020 AT 11H54CEST) ... 31

FIGURE 6:OVERVIEW OF TYPES OF DATA MANAGEMENT MODELS ... 33

FIGURE 7:REVISED CBA RESULTS ELECTRICITY SMART METERS CONSIDERING A LARGE-SCALE ROLL-OUT TO AT LEAST 80% BY 2020(AS OF JULY 2018), FIGURE MODIFIED FROM TRACTEBEL (2019) ... 39

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FIGURE 9:LEFT- SITUATION WITHOUT DR.RIGHT- SITUATION WITH DR VIA AN INDEPENDENT AGGREGATOR (IA) WITHOUT

ANY CORRECTION OR COMPENSATION ... 58

FIGURE 10:DR VIA AN INDEPENDENT AGGREGATOR (IA) WITH A PERIMETER CORRECTION OF THE SUPPLIER’S BRP ... 60

FIGURE 11:AN EXAMPLE OF DR REMUNERATION IN THE WHOLESALE MARKET IN SINGAPORE (EMA2013) ... 62

FIGURE 12:THE REGULATED (LEFT), CONTRACTED (MIDDLE) AND CORRECTED MODEL (RIGHT) FOR THE COMPENSATION OF THE SUPPLIER AND THE PERIMETER CORRECTION. ... 66

FIGURE 13:SCHEMATIC OVERVIEW OF THE BI-LEVEL MODEL SETTING ... 74

FIGURE 14:PROFILES FOR NORMAL AND CRITICAL DAYS ... 78

FIGURE 15:DISTRIBUTION NETWORK INVESTMENT SAVINGS ... 81

FIGURE 16:SYSTEM WELFARE FOR DIFFERENT DEMAND-SIDE FLEXIBILITY LEVELS ... 82

FIGURE 17:LOAD PROFILES FOR THE DIFFERENT TYPES OF CONSUMERS IN THE REFERENCE SCENARIO:(A) PROSUMERS,(B) PASSIVE CONSUMERS ... 83

FIGURE 18: LOAD PROFILES FOR THE DIFFERENT TYPES OF CONSUMERS WITH WF =0.5:(A) PROSUMERS,(B) PASSIVE CONSUMERS ... 84

FIGURE 19:LOAD PROFILE FOR THE DIFFERENT TYPES OF CONSUMERS WITH COMP=€5.33:(A) PROSUMERS,(B) PASSIVE CONSUMERS ... 86

List of Boxes

BOX 1:THE EUROPEAN HARMONISED ELECTRICITY MARKET ROLE MODEL ... 23

BOX 2:USE OF TRANSPARENCY INFORMATION BEYOND THE REGULATION – THE EXAMPLE OF ‘TOMORROW’ ... 31

BOX 3: EBIX® ROLE AND DELIVERABLES IN HARMONIZATION OF DOWNSTREAM MARKET PROCESSES IN THE EU ... 35

BOX 4:REGIONAL RETAIL MARKET HARMONISATION – THE EXAMPLE OF THE NORDICS ... 37

BOX 5:EXAMPLE OF NATIONAL DATA EXCHANGE PLATFORM –ESTONIA ... 38

BOX 6:AEUROPEAN FRAMEWORK FOR CYBER SECURITY AND DATA PROTECTION ... 41

BOX 7:ARTICLES IN THE DIRECTIVE (EU)2019/944 IN THE CEP RELEVANT FOR AGGREGATORS ... 56

BOX 8:AN EXCEPTION TO PERIMETER CORRECTION– CAPACITY PRODUCTS ENTAILING LOW (NET) ENERGY VOLUMES ... 60

BOX 9:DEMAND RESPONSE THROUGH INDEPENDENT AGGREGATION IN SINGAPORE ... 61

BOX 10:DEMAND RESPONSE THROUGH INDEPENDENT AGGREGATION IN BELGIUM ... 63

BOX 11:DEMAND RESPONSE THROUGH INDEPENDENT AGGREGATION IN SLOVENIA………..64

BOX 12:DEMAND RESPONSE THROUGH INDEPENDENT AGGREGATION IN FRANCE ... 65

BOX 13:SOCIALISATION OF (SOME OF) THE COMPENSATION COSTS ... 66

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Abbreviations

ACER Agency for the Cooperation of Energy Regulators

BIM Business Information Models

BSP Balancing Service Provider

BRP Balance Responsible Party

BRS Business Requirement Specifications

CACM GL Capacity Allocation and Congestion Management Guideline

CBA Cost-Benefit Analysis

CCC Coordinated Capacity Calculator

CCM Capacity Calculation Methodologies

CCR Capacity Calculation Region

CEEP Council of European Energy Regulators

CEP Clean Energy Package for all Europeans

CACM GL Guideline on Capacity Allocation and Congestion Management

CGM Common Grid Model

CGMES Common Grid Model Exchange Specification

CGMM Common Grid Model Methodology

CIM Common Information Model

DA Day-Ahead

DEP Data Exchange Platform

DER Distributed Energy Resources

DMM Data Management Model

DP Data Providers

DR Demand Response

DSF Demand-Side Flexibility

DSO Distribution System Operator

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EB GL Electricity Balancing Guideline

EC European Commission

ECCo SP ENTSO-E Communication and Connectivity Service Platform

EFET European Federation of Energy Traders

ENTSO-E European Network of Transmission System Operators for Electricity

ESGTF European Smart Grids Task Force

ESMP European Style Market Profile

ESO(s) European Standards Organizations

EU European Union

FCA GL Forward Capacity Allocation Guideline

FCR Frequency Containment Reserve

GDPR General Data Protection Regulation

GLDPM Generation and Load Data Provision Methodology

ICE Intercontinental Exchange

ICT Information Communication Technology

ID Intraday

IEC International Electrotechnical Commission

IGM Individual Grid Model

IL Interruptible Load

IT Information Technology

IGM Individual Grid Model

KORRR Key Organisational Requirements, Roles and Responsibilities Methodology

LLP Licensed Load Providers

MO Market Operator

MS Member State of the EU

MWh MegaWattHour

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NRA National Regulatory Authority

NTC Net Transmission Capacity

OES Operators of Essential Services

OPC Outage Planning Coordination

OPDE Operational Data Planning Environment

OPDM Operational Planning Data Management

PCN Physical Communication Network

PDO Primary Data Owner

RCC Regional Coordination Center

RDF Resource Description Framework

SGAM Smart Grid Architecture Model

SO GL System Operations Guideline

ToE Transfer of Energy

TP Transparency Platform

TSO Transmission System Operator

TYNDP Ten-Year Network Development Plan

UML Unified Modeling Language

UMM Urgent Market Message

VoLL Value of Lost Load

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Executive Summary

This deliverable consists of an introduction and two main parts. Each part consists of two sections: • Data exchange and interoperability

o Section 2.1: This section provides an in-depth description of network, market and consumer data exchange and management in Europe following requirements in the EU electricity network codes and guidelines, the Clean Energy Package and other relevant regulations like the Transparency Regulation (EU) No 543/2013.

o Section 2.2.: This section includes a contribution with the aim to structure the debate around the ongoing preparatory work for new implementing acts on interoperability requirements and procedures for access to data following Article 24(2) of the recast of the Electricity Directive (EU) 2019/944.

• Demand-side flexibility

o Section 3.1: This section provides an in-depth description of the regulatory framework around independent aggregators as laid out in the Clean Energy Package with a focus on balancing roles and responsibilities, including a discussion of implementations in different Member States.

o Section 3.2: This section includes an academic study investigating the interactions between network tariff design and explicit demand-side response, in the form of mandatory curtailment by the DSO for a fixed level of compensation.

The two main topics of this interim deliverable, data exchange and interoperability and Demand-Side Flexibility (DSF), were identified as relevant research domains in the regulatory gap analysis performed in INTERRFACE Deliverable D2.4 Completed Regulatory Framework (Schittekatte et al. 2019).1 These two topics have been listed as European priority legislations. The relevance of the

network code on Demand-Side Flexibility (DSF) has been confirmed in the priority list for new network codes for 2020-2023 published on 14 October 2020 by the European Commission. The implementing act on interoperability is described as a priority action in the European Energy System Integration Strategy published in July 2020 by the European Commission. Please note that our work around flexibility market design as part of D2.4 is also very relevant with regards to the planned new network code on DSF. We chose not to include that research in this deliverable as it is already published as part of D2.4 but we plan to integrate it, possibly including some updates, in the final deliverable of T9.4.

The research results have a two-fold purpose. First, the research results feed into the ongoing discussions at national and European level around the new European legislations. Second, the research results are of direct use for the project partners who are involved in the INTERRFACE demonstrators.

Data exchange and interoperability

The two sections of this part of the deliverable cover consecutive steps of the research process, in which we explore the fundamentals in the first part and make an informed contribution to the ongoing policy and regulatory debate in the second part.

In Section 2.1, we focus on two issues related to data exchange provisions in the network codes and other relevant European legislation: the level of harmonisation of data exchange and the level of access to data. In Section 2.1.1, we introduce the Smart Grid Architecture Model (SGAM) and use it as a generic framework to discuss the level of harmonisation of data exchange processes and the related infrastructure in the European electricity sector, and we describe high-level principles

1 INTERRFACE Deliverable D2.4 Completed Regulatory Framework is available for download at:

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concerning access to data. The SGAM is a three-dimensional model that is intended to present the design of smart grid use cases from an architectural, technology- and solution-neutral point of view. An important feature of the SGAM is its focus on interoperability, which is seen as the key enabler for smart grids. In Sections 2.1.2 and 2.1.3, we apply the framework to respectively network and market data, and consumer data. In both sections, we also discuss the level of access to the respective data. Table 1 maps the aspects we discuss related to network and market, and consumer data to the five interoperability layers of the SGAM framework. Harmonisation efforts can take place on every layer but full harmonisation is not always aimed for. Often national specifics and/or existing solutions need to be considered.

Table 1: Mapping of aspects we discuss related to network and market, and consumer

data to the five interoperability layers of the SGAM framework

SGAM Interoperability layer Typical aspects represented acc. to (SGCG, 2012a) Aspects we discuss related to network and market

data Aspects we discuss related to consumer data Business Layer

Regulatory and economic (market) structures and

policies; business

objectives and processes

Relevant provisions in the Third Energy Package, the Transparency Regulation and the network codes and guidelines

Relevant provisions in the Third Energy Package, Clean Energy Package and General Data Protection Regulation

Function Layer

Functions and services

including their

relationships

Use cases selected for the purpose of this text related to the TYNDP, the ENTSO-E Transparency Platform and the Common Grid Model for capacity calculation

Use cases and Data Management Models

Information

Layer Information canonical data models objects, Common Model and harmonised Information data format

Interoperability

requirements and data formats

Communication

Layer Communication protocols and data exchange mechanisms

ENTSO-E Communication and Connectivity Service Platform

National practices

Component

Layer Physical distribution of all participating components in a smart grid context

Physical Communication Network

When we introduce the SGAM framework in Section 2.1, we briefly touch on the aspect of interoperability. Interoperability is of increasing importance in the European discussion around retail markets, consumer data management and the provision of energy services. Interoperability is also important on transmission and wholesale market level for the implementation of data exchange requirements stemming from the electricity network codes, the Transparency Regulation (TP) and the Ten-Year Network Development Plan (TYNDP). Interoperability is often referred to as the ability of two or more devices from the same or different vendors to exchange information and use that information for correct co-operation. It is important to keep in mind that interoperability is not the objective itself, but it is the means to the end of providing better services to energy consumers. This was recognised in the Clean Energy Package, which puts interoperability on top of the European agenda.

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In Section 2.2, we focus on interoperability of energy services in Europe. The original proposal of the recast of the Electricity Directive (EU) 2019/944 in the Clean Energy Package foresaw the adoption of a common European data format for energy customer data. This was removed from the final version, which instead entitles the European Commission to adopt implementing acts specifying interoperability requirements and non-discriminatory and transparent procedures for access to data. The new acts dealing with interoperability have been established as one of three legislative priorities by the European Commission at the European Electricity Regulatory Forum (“Florence Forum”) in 2019. More recently, the priority of this act was confirmed in the European Energy System Integration Strategy published in July 2020 by the European Commission. Preparatory work for the implementing acts is already ongoing. In this section of the deliverable, we elaborate on three findings.

First, different multi-dimensional interoperability frameworks exist. While they agree that full interoperability can only be achieved if all dimensions are addressed, they do not agree on either the number of dimensions or on labelling them. We do not propose an additional framework but identify commonalities across the frameworks that need to be addressed to achieve full interoperability of energy services within the Union.

Second, experience shows that different use cases can inspire different solutions. We focus on the North American Green Button initiative for utility customer data and ENTSO-E’s experience in supporting network code requirements for the exchange of market and network data. Moreover, experience with interoperability in healthcare is very advanced and can serve as an inspiration for energy, especially regarding interoperability testing and governance.

Third, governance is a key issue in achieving interoperability. The existing governance mainly covers stakeholder dialogue and European standardisation. We provide ideas on how to use the EU interoperability acts to step up these efforts. In addition, we think governance should be extended to include formalisation of best practices, implementation monitoring and reporting, and interoperability testing. This governance could be taken on by a new EU entity.

Demand-side flexibility

To meet the ambitious European climate and energy objectives, Member States will have to increase the share of renewable energy sources (RES) in the electricity mix. An increasing part of these resources will be intermittent RES (wind and solar) creating periods of abundance and scarcity. Many of these resources are connected to low and medium voltage distribution networks. At the same time, increasing loads in distribution networks due to the electrification of transport (e.g. electric vehicles (EVs)) and heating (e.g. heat pumps) also give rise to challenges for DSOs. DSOs in charge of developing, maintaining, and running distribution networks will face higher demand and production peaks that need to be actively managed to minimise network costs while maintaining quality of service.

Flexibility, coming from both the supply and demand-side, is critical to face these challenges. While supply-side flexibility has been traditionally provided in electricity systems, demand-side flexibility, driven by new technological tools, is a more recent development. Demand-side flexibility can help to limit the need for network investment. Regulation and market design need to evolve to create a level playing field between demand and supply-side flexibility. This has been recognized in the Clean Energy Package, which states that enabling regulatory frameworks shall be implemented at the national level. Experiences at the national level feed discussions around the development a new European network code on demand-side flexibility or the amendment of existing network codes.2

2 With “a new network code on demand-side flexibility” we refer to Art. 59(1.e) Regulation (EU) 2019/943, stating

the possibility to adopt a new network code in relation to demand response, including rules on aggregation, energy storage, and demand curtailment rules.

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The two sections of this part of the deliverable on demand-side flexibility focus on two important elements of the ongoing debate around the (possible) new network code on DSF: the regulatory framework around independent aggregation and the interaction between implicit and explicit demand response. The research findings in this report complement our earlier work done around the design of flexibility markets, another important topic which is part of the same debate (Schittekatte et al. 2019).

In Section 3.1, we focus on the regulatory framework around independent aggregators. Independent aggregators have been defined in the Clean Energy Package (CEP), more specifically in Art. 2 (19) of the Directive (EU) 2019/944, as « a market participant engaged in aggregation who is not affiliated to the customer's supplier ». ‘Aggregation’ is defined as « a function performed by a natural or legal person who combines multiple customer loads or generated electricity for sale, purchase or auction in any electricity market ». Even though independent aggregators are defined in the CEP, the implementation of their regulatory framework has not been detailed. In this section, we focus on one important element of the regulatory framework, namely on the (contractual) relationship between the independent aggregator and the supplier. We find that there is a consensus in the literature and practice about the need to correct the supplier’s Balance Responsible Party (BRP) for the DR activations by the independent aggregator. However, some implementation issues remain open. In contrast, no consensus exists around the need for a compensation of the supplier for foregone energy sales. Some stakeholders argue that not enforcing a supplier compensation is a justifiable implicit subsidy for aggregators, while others point out that such practice is discriminatory and distorts competition. Most European countries with a regulatory framework for independent aggregation in place follow the latter reasoning and have implemented a compensation model. We describe three compensation models and discuss four of their properties. No model stands out; each model makes its own trade-offs. In order to facilitate cross-border aggregation, we deem that the priority should be to provide more guidance at the European level on the need for a supplier compensation over discussions about the details of the exact compensation model.

In Section 3.2 we investigate the economics of demand-side flexibility. More concretely, through a game-theoretical model, we focus on the case of mandatory curtailment by the DSO with compensation. We develop a long-term bi-level equilibrium model where the regulated DSO maximizes the social welfare while deciding on the network investment and/or consumers’ curtailment for a fixed level of compensation. Consumers that can be prosumers or passive consumers react to this while fulfilling their own electricity demand. The DSO anticipates the reaction of the consumers when investing in the network and when setting the flexibility level. Furthermore, the model assesses the interaction between implicit (network tariffs) and explicit (mandatory curtailment) demand-side flexibility. Network tariffs are set to recover the network costs and flexibility costs. We find that the economics of explicit demand-side flexibility are more positive when tariffs are cost-reflective. This implies that we cannot avoid redesigning tariffs by using explicit demand flexibility. We also find that setting an appropriate level of compensation is difficult. A high level of compensation will be gamed by prosumers relying on solar PV generation and battery storage systems.

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1. Introduction

A multitude of articles in the recast of the electricity Directive (EU) 2019/944 in the Clean Energy Package (CEP) guide Member States (MS) to innovate in new domains related to the electricity system. In short, these articles set principles lining out the boundaries for the implementation of national regulatory frameworks. These same new domains also fall within the scope of network code areas identified in Art. 59 of the recast of the electricity Regulation (EU) 2019/943 of the Clean Energy Package (CEP). Also, Directive (EU) 2019/944 foresees other types of acts that will not be adopted as new network codes but are likewise new European rules covering these new domains. The general idea is that innovation with regulation at Member State-level, triggered by the provisions in Directive (EU) 2019/944, can in the longer term serve for inspiration for new network codes, guidelines or other new EU acts, or for amendments of existing ones. In this context, INTERRFACE partner FSR/EUI has developed a research frame that is described in Deliverable D2.4 Completed Regulatory Framework (Schittekatte et al. 2019).3 More specifically, in that Deliverable D2.4, we list

five research domains, which were identified through FSR/EUI research and teaching activities on the CEP and the electricity network codes and guidelines.4 Note that the listed research topics are a

non-exhaustive collection of gaps or disputed issues in the current regulation at Member State (MS) or EU-level related to the research domain. The originally identified research domains were: - Flexibility Mechanisms

- Consumer Data Management - Framework for Aggregators

- Peer-to-peer and Community-based Energy Trade - Electro-mobility

The first research topic we focused on within the INTERRFACE project was flexibility markets, a subcategory of the research domain “Flexibility Mechanisms”. Flexibility markets are relevant to the discussions around a new network code in relation to demand response, including rules on aggregation, energy storage, and demand curtailment rules (Regulation (EU) 2019/943, Art. 59(1.e)). The research results can be found in Deliverable D2.4, and also resulted in an academic publication (Schittekatte and Meeus, 2020).

In this intermediate deliverable, we focus on the second and third research domains in the list. First, we focus on the management and exchange of different types of data, i.e. network, market and consumer, as well as interoperability. In that sense, the scope of the research domain ‘’Consumer Data Management’’ has been broadened to reach beyond consumer data. Network and market data are covered not least due to their relevance for the INTERRFACE project, see also Section 1.3. This research contributes particularly to the discussions concerning the emerging EU implementing acts on interoperability. More precisely, Article 24(2) of the Directive (EU) 2019/944 entitles the European Commission to adopt implementing acts specifying interoperability requirements and non-discriminatory and transparent procedures for access to data. Data is understood to include metering and consumption data, as well as data for customer switching, demand response and other services as specified in Art. 23(1) of Directive (EU) 2019/944. Preparatory work for the new implementing act is already ongoing.

Second, we focus on two ongoing streams of research around demand-side flexibility. The first one evolves around the regulatory framework for independent aggregation, while the second deals in more depth with the economics of demand-side flexibility. In that sense, also the scope of this

3 D2.4 is also available at http://www.interrface.eu/sites/default/files/publications/INTERRFACE_D2.4_v1.0.pdf. 4 For more information about the Clean Energy Package and the existing EU Electricity Network Codes, please

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research domain has been broadened. Together with the completed work on flexibility markets (see above), these streams of research form part of and feed directly into the ongoing discussion around a new network code on demand response, including rules on aggregation, energy storage, and demand curtailment rules. It is not yet clear what the scope of such network code will be, which is why we aim to lay some foundations for the ongoing discussions with the research conducted through the INTERRFACE project.

The link to the research domains identified in INTERRFACE

deliverable “D2.4 Completed Regulatory Framework” and to other

activities in WP9

This deliverable is part of the ongoing research activities of the Florence School of Regulation/European University Institute (FSR/EUI) in WP9 and links to the research activities in WP2. Figure 1 shows the interaction between Tasks 2.4, 9.2 and 9.4 led by FSR/EUI. Task 2.4. has set the regulatory framework for Task 9.4 and serves as input for WP3. For each research topic, the Florence School of Regulation carries out various stakeholder involvement activities in the context of Task 9.2 that inform the research carried out in Task 9.4.

Figure 1: Interrelation between INTERRFACE tasks 2.4, 9.2 and 9.4 led by FSR/EUI

Stakeholder involvement and management is a reciprocal process between the project partners and relevant stakeholder group. On the one hand, stakeholder involvement and management are critical components of the successful delivery of any project such as INTERRFACE in its entirety. On the other hand, stakeholder engagement can also significantly drive progress in research through hands-on feedback about real-life implementation of proposed concepts and frameworks. A comprehensive description of the INTERRFACE strategy for stakeholder involvement and management is provided in Deliverable D9.4 Yearly Exploitation Report and Business Plan Update 1. The dissemination and stakeholder involvement activities conducted for each research topic are described in more detail below.

Data exchange and interoperability

Section 2.1 of this deliverable on network, market and consumer data and data exchange was published as a chapter of a Technical Report in July 2020 (Schittekatte et al. 2020), following a Florence School of Regulation online training on the EU electricity network codes and guidelines. In the context of the related online training, EUI/FSR also organised an online expert panel in November 2019 to discuss different elements of network, market and consumer data management and data exchange with policymakers and regulators, TSO, DSOs and the industry.

Section 2.2 of this deliverable on interoperability and the upcoming EU interoperability acts was published as an FSR Policy Brief in July 2020 (Reif and Meeus 2020). In May 2020, FSR/EUI presented

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the Policy Brief at the Florence School of Regulation’s Policy Advisory Council (closed door event) and discussed the future pathway towards interoperability of energy services in Europe with an expert panel consisting of policymakers, regulators, industry, and other stakeholders. In July 2020, FSR/EUI organised an online debate on interoperability of energy services together with representatives of the TSOs community and industry.5 In January 2021, FSR/EUI organised an online

event in the context of the “FSR insights” series to discuss ongoing research on interoperability with an academic panel consisting of academics from other sectors.6 In all FSR/EUI online events, the

audience is typically composed of academics, TSO-DSO representatives, industry representatives, and regulators.

Demand-side flexibility

Section 3.2 was published as an FSR working paper in July 2020 (Nouicer et al. 2020b) and has been submitted to an academic peer-reviewed journal. Moreover, an online event was organised to discuss the research results with a panel of two regulators (from Flanders and Norway) who wrote a relevant CEER report on the same topic.7 Dissemination activities regarding the work about the regulatory

framework around independent aggregation are planned for 2021.

Note also that significant stakeholder engagement activities were conducted for the research topic of flexibility mechanisms and flexibility markets which is another important topic with regards to the possible new network code on Demand-Side Flexibility (DSF) (Schittekatte and Meeus, 2020). EUI/FSR organized an online debate with representatives of innovators and startups active in flexibility markets for its network of alumni. At the Florence School of Regulation’s Policy Advisory Council (closed door event) a session was organised around flexibility markets featuring a panel of three regulators (from Great Britain, Slovenia and the Netherlands) to provide a regulatory perspective. The audience consisted of academics, TSO-DSO representatives, industry, policy makers and regulators. Importantly, the findings of this research were also presented on the Energy Infrastructure Forum organized by the European Commission in Copenhagen on 23-24 of May 2019 in the session ‘’ TSO-DSO cooperation for the future of energy infrastructure planning’’. Lastly, the research was also featured in the above described online event with regulators active in CEER.

Research methodology

Throughout the INTERRFACE project, more specifically in T9.4 (‘Foundations for the adoption of new network codes’), selected research topics are scrutinized. As was also described in Deliverable 2.4, the research methodology generally consists of multiple steps to address the identified research topics. The steps can differ slightly per topic.

Section 2 of this deliverable on data exchange and interoperability consists of two parts that are closely related and form two steps of the research process on the same topic.

• In Section 2.1, we explore the fundamentals by providing an in-depth description of network, market and consumer data exchange and management in Europe following requirements in the network codes and guidelines, the Clean Energy Package and other relevant regulations like the Transparency Regulation (TP) or the General Data Protection Regulation (GDPR).

5 The recording of the online debate and a summary of the event highlights are available at

https://fsr.eui.eu/event/facilitating-interoperability-of-energy-services-in-europe/.

6 The event page is available at

https://fsr.eui.eu/event/digitalization-of-energy-infrastructure-and-data-interoperability-what-can-we-learn-from-telecom-and-healthcare/.

7 CEER Paper on DSO Procedures of Procurement of Flexibility (16 July 2020), link:

https://www.ceer.eu/documents/104400/-/-/f65ef568-dd7b-4f8c-d182-b04fc1656e58 . Highlights and recording of the event: https://fsr.eui.eu/how-to-unlock-the-flexibility-potential-in-electricity-systems-a-regulatory-debate/

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• In Section 2.2, we make an informed contribution to the current policy and regulatory debate and the ongoing preparatory work for new implementing acts on interoperability requirements and procedures for access to data following Art. 24(2) of the recast of the Electricity Directive (EU) 2019/944. Our contribution aims to structure the debate by highlighting three issues that likely need to be considered for the upcoming implementing acts.

Section 3 of this deliverable integrates two research streams around the topic of demand-side flexibility.

• In Section 3.1, we take stock of the regulatory framework for independent aggregators. We look at the issue of the perimeter correction and the compensation between the independent aggregator and the supplier. We describe three compensation models and discuss four of their properties. We discuss whether there is already a consensus found at EU-level regarding these discussions. The research helps to inform the debate at the European level around the need for further guidance for the framework for independent aggregation, which might be a topic covered by the new network code on demand-side flexibility.

• In Section 3.2 we go more into depth on the economics of demand-side flexibility. More concretely, through a game-theoretical model, we focus on the case of mandatory curtailment by the DSO with compensation. We develop a long-term bi-level equilibrium model where the regulated DSO maximizes the social welfare while deciding on the network investment and/or consumers’ curtailment for a fixed level of compensation. We also draw recommendations for demand-side flexibility in the use case of distribution network investment savings. The results on the interaction between explicit demand-side flexibility and network tariffs contribute to the ongoing debate about the interaction between different tools to activate demand-side flexibility.

Relevance for other work packages in INTERRFACE

Data exchange, management and interoperability are core topics of the INTERRFACE project and its aim to develop an Integrated Pan-European Grid Services Architecture (IEGSA). The findings of Section 2 can inform the decisions made in WP3 on the INTERRFACE system architecture design (functional and technical). It can also serve as an input for the demos within the INTERRFACE project. More specifically, the analysis of the current status of data exchange and management in the first part (Table 1) shows how different software and hardware are currently used to manage data flows in the different parts of the electricity value chain. Also, with increasing system complexity on all levels of grid and market operation, be it transmission or distribution level, wholesale or retail markets, interoperability will become more and more important. This has been recognised some time ago for data exchanges related to TSOs, RSCs and ENTSO-E and has now also been put on top of the European agenda for data exchanges that directly concern (end)-consumers.

Demand-side flexibility and, specifically, the regulatory framework for independent aggregation are relevant topics for the INTERRFACE project. One of the core project aims is to provide new services, market rules and coordination functions for pooling and allocating distributed flexibility, stemming from distributed energy resources, demand aggregators and grid assets. INTERRFACE demonstrators aim to implement solutions for a seamless pan-European electricity market to which all market participants, incl. those that use intermediaries such as aggregators, have access to provide energy services. The findings of Section 3 inform INTERRFACE demonstrators, which aim to unlock (demand-side) flexibility via aggregation, about the implementation of an appropriate regulatory framework for independent aggregation and the relevant practical implementation challenges.

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2. Data exchange and interoperability

Network, market and consumer data and data exchange in existing EU

legislation

Data is becoming a key commodity in the electricity sector and data management is increasingly important for all actors involved.8 Driven by market integration, more and more network and

wholesale market data is exchanged at transmission-level among TSOs, RSCs and ENTSO-E and the overall level of harmonisation is high.9 At distribution-level, data volumes are increasing due to the

deployment of smart grids and smart metering systems. New consumer rights to download and share their own energy data with third parties increase the need to efficiently organise the exchange of and the access to energy consumer data. Currently, practices related to consumer data are widely divergent across Member States.

This part of the deliverable looks at data exchange provisions in the network codes and other relevant European legislation such as the Clean Energy Package (CEP).10 Please note that the

descriptions are not necessarily exhaustive. We focus on two issues: the level of harmonisation of data exchange and the level of access to data. In Section 2.1.1, we introduce a generic framework to discuss the level of harmonisation and describe high-level principles concerning access to data. In Sections 2.1.2 and 2.1.3, we apply the framework to respectively network and market data, and consumer data. In both sections, we also discuss the level of access to the respective data.

This part of the deliverable was published as a chapter of a Technical Report (Schittekatte et al. 2020) in July 2020, following a Florence School of Regulation online training on the EU electricity network codes and guidelines. In the context of the related online training we also organised an online expert panel in November 2019 to discuss different elements of network, market and consumer data management and data exchange.

Framework to discuss the issues related to data

This section is split into two parts. Subsection 2.1.1.1 discusses the aspects of data exchange that could be subject to harmonisation. Subsection 2.1.1.2 looks at the aspects of access to data that could be subject to regulatory requirements.

Aspects of data exchange potentially subject to harmonization

The electricity system can be described as a ‘system of systems’, that means it consists of multiple, smaller or larger systems that need to share information by means of exchanging data between their Information Technology (IT) systems. The challenge with such complex systems is that they are not built from scratch. Rather, the integration of electricity networks and markets takes place gradually

8 Data is the ‘representation of facts as text, numbers, graphics, images, sounds or videos. These facts are captured,

stored and expressed as data.’ Information is ‘data in context. Without context, data are meaningless; we create meaningful information by interpreting the context around the data. The context includes the business meaning of data elements and related terms; the format in which the data are presented; the timeframe represented by the data; and the relevance of the data to a given usage’ (ENTSO-E et al., 2016). Data management encompasses the processes

by which data is ‘sourced, validated, stored, protected and processed, and by which it can be accessed’ (CEER 2016). 9 RSCs perform tasks related to TSO regional coordination, including coordinated security analysis, coordinated capacity calculation, improved individual/common grid model delivery, short-term adequacy and outage planning coordination. RSCs will be replaced by Regional Coordination Centres (RCCs) by 1 July 2022 as is required by the e-Regulation Art. 35(2)).

10 In this part of the deliverable, we refer to the recasts of the e-Directive and e-Regulation adopted as part of the

Clean Energy Package when we say ‘e-Directive’ and ‘e-Regulation’. References to earlier versions are explicitly highlighted.

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and new networks, systems, devices, applications or components must be integrated into the existing system. As a result, IT systems from different vendors are in place across the electricity system, often even within the same company.

The traditional way to interconnect these IT systems that often use proprietary data exchange formats is to build specialised interfaces. Uslar et al. (2005) state that ‘building specialized adaptors for interconnection between the systems is the most common and time-consuming task for IT departments at energy companies.’ To address this issue and to support European smart grid deployment, the European Commission issued the Smart Grid Standardisation Mandate M/490 to the European Standardisation Organisations CEN-CENELEC-ETSI in 2011. The mandate’s objective was to develop or update a set of consistent standards within a common European framework to achieve interoperability and enable or facilitate the implementation of different smart grid services and functionalities in Europe. Thereby, different digital computing and communication technologies and electrical architectures, and associated processes and services could be integrated. One result of the mandate was the Smart Grid Architecture Model (SGAM) framework that can be used to identify standardisation gaps, required use cases and security requirements.11

The SGAM is a three-dimensional model that is intended to present the design of smart grid use cases from an architectural, technology- and solution-neutral point of view (SGCG 2012). An important feature of the SGAM is its focus on interoperability, which is seen as the key enabler for smart grids. According to IEC 61850-2010, interoperability refers to the ‘ability of two or more devices from the

same vendor, or different vendors, to exchange information and use that information for correct co-operation’. The SGAM framework consists of five abstract interoperability layers which represent

business objectives and processes, functions, information exchange and models, communication protocols, and components as summarised in Table 2. Since its development, the SGAM framework has been used in several European and national R&D projects (see Uslar et al. (2019) for an overview).

Table 2: Mapping of aspects we discuss related to network and market, and consumer

data to the five interoperability layers of the SGAM framework

SGAM Interoperability layer Typical aspects represented acc. to (SGCG, 2012a) Aspects we discuss related to network and market

data Aspects we discuss related to consumer data Business Layer Regulatory and economic (market) structures and policies; business objectives and processes Relevant provisions in the Third Energy Package, the Transparency Regulation and the network codes and guidelines

Relevant provisions in the Third Energy Package, Clean Energy Package and General Data Protection Regulation Function Layer Functions and services including their relationships

Use cases selected for the purpose of this text related to the TYNDP, the ENTSO-E

Transparency Platform and the Common Grid

Use cases and Data Management Models

11 Please see a figure of the SGAM framework on page 30 of the report by SGCG (2012a), available at

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Model for capacity calculation

Information Layer

Information objects, canonical data models

Common Information Model and harmonised data format

Interoperability requirements and data formats

Communication

Layer Communication protocols and data exchange mechanisms ENTSO-E Communication and Connectivity Service Platform National practices Component Layer Physical distribution of all participating components in a smart grid context

Physical Communication Network

In this chapter, the SGAM serves as a framework to discuss the level of harmonisation of data exchange processes and the related infrastructure in the European electricity sector (see Table 2). Harmonisation efforts can take place on every layer but full harmonisation is not always aimed for. Often national specifics and/or existing solutions need to be considered. Note that, for the purpose of this Deliverable, the current use case selection regarding network and market data is limited to the transmission domain.

Aspects of access to data potentially subject to regulatory requirements

With 200 million smart meters for electricity expected to be installed by 2020 (ENTSO-E, 2019a) and both transmission and distribution grids becoming more digitalised, questions on how to manage the increasing amounts of network, market and consumer data arise. Clarity is needed on who has access to which type of data and for which purpose. The Clean Energy Package requires Member States to ensure the highest level of cybersecurity and data protection as well as the impartiality of the entities processing the data.

Data access is highly regulated. While access to network and market data is mostly subject to European regulation, access to energy consumer data is regulated on a national level. For network and market data, access can be divided into restricted access, open access with exceptions and open access without exceptions. The latter relates to transparency obligations of TSOs, DSOs, production, generation or consumption units, operators of direct current links, power exchanges, and operators of balancing markets. For consumer data, access can be divided into access of the consumer to her own data and access of eligible parties to consumer data. Until recently, such data was of interest mostly for DSOs and suppliers for traditional retail services such as billing or supplier switching. With the increasing deployment of smart meters and consumer empowerment through new rights, services based on data sharing with third parties are on the rise and access to consumer data is increasingly in the focus of regulators.

Among the aspects of access to data that are potentially subject to regulatory requirements are data protection, cyber security, transparency and publication of data, and roles and responsibilities of data handling entities to ensure non-discriminatory access and to prevent distortion of competition.

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Applying the framework to network and market data

This section consists of two parts. In Subsection 2.1.2.1, we look at the level of harmonisation regarding network and market data on the European level. In Subsection 2.1.2.2, we discuss the level of transparency of and access to network and market data.

2.1.2.1 Level of harmonisation

In what follows, we discuss harmonisation efforts on a layer-by-layer basis. The business layer refers to provisions in relevant legislation. The function layer covers selected use cases. On the information layer, the Common Information Model (CIM) and the harmonised data format are described. The communication layer describes the existing communication platform ‘ENTSO-E communication and Connectivity Service Platform’ (ECCo SP). The component layer looks at the development of a dedicated Physical Communication Network (PCN).

Business Layer: Relevant provisions in the Third Energy Package, the Transparency Regulation

and the electricity network codes and guidelines

Until around one decade ago, pan-European network and electricity market data were only available to a limited audience (Egerer et al. 2014). The Third Energy Package set in motion a process towards greater transparency of network and market data, thereby increasing the need for data exchanges and common processes and technical solutions to facilitate these exchanges. Regulation (EC) No 714/2009 required ENTSO-E to adopt a non-binding Community-wide Ten-Year Network Development Plan (TYNDP) based on national investment plans and taking into account regional investment plans every two years (EC 2009b).12 Regulation (EU) No 543/2013 (in the following

‘Transparency Regulation’) required ENTSO-E to create a Transparency Platform for the central collection and publication of data relating to generation, transportation and consumption of electricity for the whole ENTSO-E area (EC 2013).13 Both projects require more than 40 TSOs across

Europe to send data to a central platform. Later, the market and system operation guidelines were the starting point for additional projects that further increased the need for seamless data exchanges among TSOs, RSCs and ENTSO-E.14

Function Layer: Selected use cases

Three uses cases are selected by the authors for the purpose of this text to illustrate the complexities around data exchanges among TSOs, RSCs and ENTSO-E: the publication of data on the ENTSO-E Transparency Platform, the building of the Common Grid Model (CGM) for capacity calculation purposes, and the development of the Ten Year Network Development Plan (TYNDP). Depending on

12 ‘National investment plans’ refers to national network plans that TSOs need to submit annually to the respective

NRA, as required by Directive 2009/72/EC (EC 2009a).

13 The ENTSO-E transparency platform is available at https://transparency.entsoe.eu/. Hirth et al. (2018) list other

sources for power system data, e.g. ENTSO-E’s data portal/power statistics, Eurostat, national statistical offices as well as data collected from individual TSOs’ websites. Note that the Transparency Regulation (EU) No 543/2013 is binding in its entirety and directly applicable in all Member States but is not fully binding for non-EU TSO members of ENTSO-E.

14 Projects in the area of the market codes include SDAC/SIDC, the balancing platforms, and the Single Allocation

Platform (JAO). An example for a project in the area of the operation codes is Coordinated Security Analysis. Some projects also cross the two domains, such as Coordinated Capacity Calculation, the Common Grid Model, Short-Medium Term Adequacy Forecast, (regional) outage coordination, or publications to ACER.

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the use case, different types of data need to be exchanged as illustrated Table 3. Note that none of the selected use cases includes the exchange of real-time data.15

Table 3: Selected use cases and relevant types of data

ENTSO-E Transparency Platform

Common Grid Model

for capacity calculation TYNDP Network data16 none Structural and forecast

data17

Structural and forecast data174

Market data Forecast, scheduled and actual data Forecast and scheduled data Forecast data

Four types of non-real-time data can be distinguished. Structural data means general and permanent data of the assets, e.g. characteristics, attributes and capabilities.18 Scheduled data

means data on outage planning, on generation-load programs or on the exchange of electricity for a given time period. Forecast data refers to the best estimate of market conditions or operational conditions of the transmission system for a given timeframe. Actual data means ex-post data published after the operating period, e.g. data related to realised generation-load programs, cross-zonal physical flows, congestion management measures, or volumes and prices of activated balancing reserves.

ENTSO-E Transparency Platform

On its Transparency Platform, ENTSO-E publishes fundamental close-to-real-time market data on load, generation, transmission, balancing, outages and congestion management. ENTSO-E is the platform operator, while the data itself is provided by Primary Data Owners (PDO).19 Most PDOs do

not provide their data directly to ENTSO-E but through intermediaries, called Data Providers (DP). The data flows as follows: PDO to DP to ENTSO-E’s TP to data users.20

15 Article 42(1) of the SO GL states that real-time data exchange between TSOs of the same synchronous area shall

be done using the IT tool for real-time data exchange at pan-European level as provided by ENTSO-E. This is an existing tool called ‘ENTSO-E Awareness System (EAS)’. TSOs also exchange real-time data via their supervisory control and data acquisition (SCADA) systems and energy management systems (SO GL, Art. 42(2)). The component layer provides more details on the infrastructure for real-time data exchange.

16 In this text, we understand network data as the equivalent of the data needed to create grid models.

17 The Common Grid Model Methodologies refer to forecast network data as variable data needed to incorporate

up-to-date operating assumptions. Examples are settings for various items of equipment needed to describe the forecasted behaviour of the transmission system, including variable data on grid topology, energy injections and loads, operational limits, control settings of regulating equipment, and assumptions on adjacent grids.

18 Examples for structural data can be found in Article 48 of the SO GL or the Generation and Load Data Provision

Methodologies pursuant to CACM GL and FCA GL.

19 The Transparency Regulation defines PDOs per data category. PDOs can be TSOs (or, if applicable, transmission

capacity allocators), DSOs, production, generation or consumption units, operators of direct current links, power exchanges, and operators of balancing markets.

20 At the time of writing, more than 50 DPs (incl. all TSOs and most PXs), several thousand PDOs and around 13,000

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Depending on the type of data and the time-frame it covers, the publication deadline for ENTSO-E varies.21 Note that some of the intermediaries (e.g. Nord Pool) operate their own transparency data

platforms to fulfil requirements under the REMIT Regulation (EC 2011), which can create overlaps with the ENTSO-E TP.22 Other issues identified with the Transparency Platform are related to gaps

in data availability, timeliness of data publication, the usability of the available data and inconsistent interpretation of data definitions by different data providers (EC 2017a; Hirth et al. 2018).23 Art. 4(1)

of the Transparency Regulation states that PDOs themselves shall ensure that the data they provide to TSOs or to DPs are complete and of the required quality. NRAs shall ensure that the PDOs, TSOs and DPs comply with their obligations under the Regulation (Art. 4(6)). Note that the liability of the PDOs, the DPs and ENTSO-E is limited to cases of gross negligence and/or wilful misconduct and in any event the parties shall not be liable to compensate the person who uses the data (Art. 18).

Common Grid Model for capacity calculation

In the following, we provide a short summary of the interplay between the Common Grid Model (CGM) and coordinated capacity calculation. The creation of a CGM is a pan-European process to be completed by all TSOs in coordination with merging agents as shown in Figure 2. The role of merging agents was allocated to Regional Security Coordinators (RSCs) (ENTSO-E, 2019e; 2019j). The CGM represents one input for coordinated capacity calculation.24 Coordinated capacity calculation is

carried out per Capacity Calculation Region (CCR) by a Coordinated Capacity Calculator and can be divided into three sequential steps for the Day-ahead (DA) and intraday (ID) timeframes pursuant to Guideline on Capacity Allocation and Congestion Management (CACM GL) (Art. 27-30): creation of a CGM out of Individual Grid Models (IGMs), regional calculation of cross-zonal capacity, and validation and delivery of cross-zonal capacity.

Figure 2: High-level illustration of data exchange processes for capacity calculation

purposes pursuant to Art. 27-30 of the CACM GL

21 A detailed data description is available at

https://www.entsoe.eu/fileadmin/user_upload/_library/resources/Transparency/MoP%20Ref02%20-%20EMFIP-Detailed%20Data%20Descriptions%20V1R4-2014-02-24.pdf.

22 Article 4(5) of the Transparency Platform states explicitly that data can also be published on TSOs’ or other parties’

websites. ACER is legally obliged to provide opinions on the ENTSO-E TP and on revisions to it. In its opinion No 02/2017, ACER (2017c) gave a recommendation on how to deal with the interactions between the different platforms. It is acknowledged that several market parties publish their inside information on the TP. According to ACER, if ENTSO-E does not want the TP to act as an inside information platform, this has to be clearly communicated to the ENTSO-E members so that market participants can use other platforms to comply with REMIT obligations.

23 A survey commissioned by the EC (2018c) showed that ‘Outages’ was perceived as the data domain with the most

gaps. Outages must be timely reported in the form of Urgent Market Messages (UMMs) and a lack/ inconsistency thereof is a concern for market parties who inform their trading decisions based on UMMs.

24 In its decision on the Core CCM, ACER (2019d) states that the Common Grid Model is also considered as a capacity

calculation input. However, the methodology governing its establishment is defined in the Common Grid Model Methodologies (CGMMs), thus falls outside the scope of the Capacity Calculation Methodologies (CCMs).

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Important to note is that the creation of pan-European CGMs and the implementation of coordinated tasks such as capacity calculation do not necessarily mean full harmonisation in terms of their geographical scope or regarding the related processes, interfaces and tools. First, harmonisation differs depending on the geographical scope. While the CGM is created on a pan-European level, capacity calculation is currently done regionally per CCR with Capacity Calculation Methodologies (CCMs) being unharmonised across different CCRs.25 For DA and ID timeframes, the envisaged level

of geographical harmonisation is high, as the CACM GL foresees a step-wise integration of CCRs towards the target flow-based approach. For long-term capacity calculation, the geographical level of harmonisation is lower as the Forward Capacity Allocation Guideline(FCA GL) (Art. 10(2)) does not prefer one calculation approach over the other and does not foresee the merging of CCRs in the future. Nevertheless, second, the capacity calculation processes across the different timeframes are based on similar input and output data. For example, each TSO must comply with the Common Grid Model Methodologies (CGMMs) and provide harmonised IGMs to the respective merging agent for the merging process.

Given the number of TSOs, RSCs, CCRs and capacity calculation timeframes, the harmonisation of processes and interfaces provides benefits, for example facilitating the provision of large volumes of data across timeframes to ACER. As such, it makes sense that the architecture of the software tools used to exchange relevant data enables the use of a common terminology to ensure interoperability. Among the elements of such common terminology are the use of common terms and definitions and a common role model. An agreement on the terms and definitions for a specific business process such as capacity calculation allows for a common understanding among all parties involved in that business process. The use of a common role model enables the definition of data exchanges independent of specific implementations in a certain Member State or CCR. It is generally important to define data exchanges between harmonised roles to avoid lock-in effects of certain functions or responsibilities by specific parties and to facilitate comparability of different implementations, for example, between CCRs that apply different capacity calculation approaches. On the European level, the Harmonised Electricity Market Role Model has been elaborated as described in Box 1.

Box 1: The European Harmonised Electricity Market Role Model

The Harmonised Electricity Market Role Model (HEMRM) has been developed and is maintained by ebIX®, EFET and ENTSO-E to facilitate the dialogue between market participants from different countries (ENTSO-E, 2018i; ebIX, EFET, ENTSO-E, 2020; ESGTF, 2019).26 It is not a model of the electricity market, but represents a model of the roles that are

related to information exchange.

The model decomposes the electricity market into a set of commonly defined roles and domains. Having such a model is necessary because, on the one hand, a single party in the market may assume multiple roles. On the other hand, in decentralised competitive markets, every role can be taken up by a different party. To construct information exchange processes, it is necessary to clearly define the roles and to design business processes so that they satisfy the requirements of harmonised roles and not those of specific parties.

In other words, the application of the model ensures that the information exchanged between real parties corresponds to a process managed within the electricity market between distinct roles that are assumed by specific parties. For example, as described above it was decided that

25 As can be seen from the fact that, initially, only CORE CCR and Nordic CCR intend to implement a flow-based

approach, Hansa CCR aims at a hybrid approach and all other CCRs currently rely on a CNTC approach (ENTSO-E, 2019e).

26 The latest version of the European Harmonised Electricity Market Role Model document is available at

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the role of coordinated capacity calculator, to whom the common grid models ultimately need to be delivered, is allocated to the specific party RSC. In the role model, the provision of grid models is defined as the relationship (the arrow) between the harmonised roles “system operator” and “coordinated capacity calculator” as shown in Figure 3. Note that the model does not present all relationships but highlights only the major ones that justify the presence of a role or an object.

Figure 3: Illustration of harmonised roles in the HEMRM relevant for delivery of

grid models

Ten-Year Network Development Plan

The development of the Ten-Year Network Development Plan (TYNDP) is a process that occurs every two years and is carried out in multiple stages, including for example the collection of relevant data from TSOs by ENTSO-E, the definition of scenarios and stakeholder involvement through public consultation. Market data is essential for the set of scenarios that are the basis of the TYNDP. Each scenario represents a possible future for the European power system and contains forecast data on installed generation capacities per technology and country, consumption profiles, border reference capacities and assumptions for generator efficiencies, fuel prices and CO2 prices. Some of the

scenarios are based on collection of national data while others are the result of pan-European optimisations. Note that the TYNDP of 2018 was the first for which the ENTSOs for gas and electricity jointly developed the set of scenarios, a practice which they will continue to follow in the future.

Information Layer: Common Information Model and harmonised data format

This section is split into two parts. First, without going too far into the technical details, we focus on key points that are important to understand the differences between network and market data. Second, we discuss the application of the Common Information Model (CIM) to enable communication between the network and market domains.

The difference between network and market data

Network and market data are fundamentally different in their complexity, which results in the application of different data models and formats as shown in Table 4.

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